[The following message consists of the notes I prepared for a
presentation this week, at Fort Ord, on Long-Term Risk Management at UXO
sites. Please recognize, however, that many of the same approaches are
applicable to short-term risk management - that is, how to protect
public safety before remedies are implemented. - Lenny Siegel]
As I see it, there is a hierarchy of responses for UXO.
A. Removal
B. Land Use Controls
C. Access Controls
D. Education
REMOVAL (in the physical sense, as opposed to a CERCLA "removal action")
is somewhat obvious. If we can find and remove UXO in a cost-effective
way, we do it. But we're never sure that we've removed all of it. And
sometimes decision-makers decide that removal is too costly, technically
impractical, and/or environmentally destructive. This is at the top of
the hierarchy because if there is no UXO there is no explosive risk.
Removal decisions are the most controversial. Largely because of the
resource implications, the armed services and others often disagree over
the breadth and depth of clearance. But even when there are differences
over removal decisions, the parties can and should work together in the
other three areas.
LAND USE CONTROLS are designed to prevent excavation or other activities
that may expose or bring people into contact with buried ordnance. There
are many possible mechanisms for restricting such activity, including
zoning and deed restrictions. Ideally they work in two ways:
1. Regular review. Responsible officials should periodically review the
property to ensure that no activity violates land use restrictions. This
should occur much more frequently than the five-year review - perhaps
quarterly. Though technically not a land use control, responsible
officials should (on the same regular schedule) also determine whether
geophysical processes such as freeze-thaw, tidal action, or erosion are
likely to expose or bring people into contact with UXO.
2. Trigger mechanisms. Requests for building permits or one-call
inquiries (for utility trenching etc.) should flag a warning, to be
followed up by responsible officials. The proper response might be
construction support, a form of removal. Or the proposed excavation
might be denied. This should be in place for "open space" parcels as
well as developing ones. At major installations, it should be possible
to record parcel-specific information about UXO deposition and know
removal activities in an easily accessible GIS data base.
ACCESS CONTROLS are particularly important on undeveloped property where
surface or near-surface (to one foot) ordnance is likely to be found.
They should designed to prevent people from coming into contact with
UXO. Visual contact is almost as dangerous as physical contact, since
UXO attracts attention. If geophysical processes are likely at the site,
then deeper ordnance is a cause for concern. At a minimum, access
controls include signs and fences. Those should be checked periodically
(quarterly?) for their integrity.
In many cases - whether or note there are fences and signs - active
patrolling should be used. That's what has kept people off of active
bases. Ideally, patrolling can be carried out by law enforcement
officials, park rangers, or others responsible for the new use. Often,
patrolling should be accompanied with clear criminal penalties for
trespassing in dangerous areas.
There is not a great body of knowledge of how well access controls are
likely to work, so community input in critical in planning them.
EDUCATIONAL PROGRAMS should be designed to discourage people from
entering dangerous areas and to warn people not to touch or even
approach suspicious objects. These can include displays at trailheads,
videos and comic books for kids, brochures, etc. As with access
controls, we don't really know what educational approach works best. So
again, the community should play a key role in devising it.
***
Land use controls, access controls, and educational programs should all
be monitored regularly to ensure viability, and the property should be
monitored for geophysical activity as well. Any time breakdown occurs,
additional removal should be considered. That is, one shouldn't wait for
a five-year review.
Therefore, long-term risk management requires a clear assignment of
responsibility (in decision documents), funding (to be arranged or even
endowed at the time of response selection), and public awareness. That
is, there should be ironclad assurances that risk management activity
will take place for the life of the UXO - usually that means
indefinitely. The public should be kept fully aware so it can ensure
that officials are taking necessary protective actions.
If long-term risk management appears to be too costly, then additional
removal should be considered, not only during the initial response
decision-making process, but at each five-year review. It's quite
possible that new technologies will lower the cost of removal, make
removal more reliable, or even prove that earlier removals were
sufficiently reliable to abandon some of the long-term management
activities.
--
Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org
http://www.cpeo.org
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